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Property Deal Addition Fails for Breach of Section 153C Time Limits
Case Law Details
- TaxGuru Citation
- 2026 taxguru.in 1664
- Case Name
- Rajesh Gandhi Vs Sanghpriya Singh (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2019-20
- Courts
- All ITAT, ITAT Delhi
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Rajesh Gandhi Vs Sanghpriya Singh (ITAT Delhi)
153C Addition for Property Deal Quashed as AY 2012-13 Falls Outside Permissible Ten-Year Search Block
Based on a seized receipt found in a 2020 search of a third party, the Assessing Officer invoked section 153C and added ₹68 lakh under section 68 for AY 2012-13, alleging unaccounted consideration in sale of a flat by the assessee.
Before the Tribunal, the assessee contended that the proceedings were time-barred. Crucially, the Revenue could not produce any satisfaction note under section 153C showing when the seized material wa...





